Li v. Ashcroft,
389 F.3d 892, 897 (9th Cir. Nov. 19, 2004) (federal conviction
of making a false claim against the United States, in violation
of 18 U.S.C. § 287, is divisible with respect to the fraud
offense aggravated felony defined in INA § 101(a)(43)(M)(i),
8 U.S.C. § 1101(a)(43)(M)(i), since even though it does require
some intended loss, "no particular amount of intended
loss is required," and so does not automatically satisfy
the element of this aggravated felony definition requiring
a loss to the victim(s) in excess of $10,000, so the record
of conviction must be examined to determine whether the conviction
falls within the definition).